Pursuant to the provisions of the Federal Trade Commission Act, as amended, (15 U.S.C.
Section 41, etseq.) and by virtue of the authority vested in it by said
Act, the Federal Trade Commission, having reason to believe that South Lake Tahoe Lodging
Association (hereinafter "respondent") has violated the provisions of Section 5
of the Federal Trade Commission Act, and it appearing to the Commission that a proceeding
by it in respect thereof would be in the public interest, hereby issues this complaint
stating its charges as follows:

PARAGRAPH ONE: Respondent South Lake Tahoe Lodging Association is a
corporation organized, existing and doing business under and by virtue of the laws of the
State of California, with its principal place of business located at P.O. Box 5746, South
Lake Tahoe, California 96157.

PARAGRAPH TWO: Respondent is a trade association representing the
interests of motel and hotel operators and other operators of lodging properties in the
South Lake Tahoe area. For purposes of this Complaint, the South Lake Tahoe area comprises
those portions of El Dorado County, California, and Douglas County, Nevada, lying within
the Lake Tahoe basin. Respondent's members are generally engaged in the offering of
short-term lodging in the South Lake Tahoe area. Respondent has approximately 63 members,
who, together with certain of respondent's associate members, constitute approximately 70
percent of the available lodging units in the South Lake Tahoe area. Except to the extent
that competition has been restrained as alleged herein, respondent's members have been and
are now in competition among themselves and with other motels, hotels, and lodging
properties.

PARAGRAPH THREE: Respondent is organized for the purpose of guarding
and fostering the interests of its members. Respondent engages in activities that further
its members' pecuniary interests. By virtue of its purposes and activities, respondent is
a corporation within the meaning of Section 4 of the Federal Trade Commission Act, 15
U.S.C. § 44.

PARAGRAPH FOUR: Respondent's acts and practices, including the acts
and practices alleged herein, are in or affecting commerce, as "commerce" is
defined in the Federal Trade Commission Act, 15 U.S.C. § 44.

PARAGRAPH FIVE: Respondent has been and is acting in agreement,
combination or conspiracy with its members, or in agreement, combination or conspiracy
with some of its members, to restrain trade in the offering of lodging in the South Lake
Tahoe area by eliminating the posting of signs advertising the prices at which its
individual members offer such lodging.

PARAGRAPH SIX: The purposes or effects of the agreement, combination
or conspiracy and respondent's acts or practices as described in Paragraph Five are and
have been to restrain competition unreasonably and to deprive consumers of the benefits of
competition in one or more of the following ways, among others:

(a) by foreclosing, reducing and restraining competition among providers of lodging in
the South Lake Tahoe area;

(b) by depriving consumers of truthful information concerning the prices of lodging in
the South Lake Tahoe area; and

(c) by depriving consumers of the benefits of competition among providers of lodging in
the South Lake Tahoe area.

PARAGRAPH SEVEN: The aforesaid acts and practices constitute unfair
methods of competition in or affecting commerce in violation of Section 5 of the Federal
Trade Commission Act, 15 U.S.C. § 45. These acts and practices are continuing and
will continue in the absence of the relief requested.

IN WITNESS THEREOF, the Federal Trade Commission on this
day of , 1998, issues its complaint against said respondent.